Capital gains exemption for transfers between holding companies and wholly owned subsidiaries depends on shareholding conditions and continues only if ownership remains intact. Transfer of a capital asset, other than stock-in-trade, between a holding company and its wholly owned subsidiary, or by a subsidiary company to its holding company, is treated as not regarded as a transfer for capital gains purposes where the subsidiary is an Indian company and the relevant shareholding conditions are satisfied. The transferee takes the cost to the previous owner, and the period of holding of the previous owner is included. The exemption is withdrawn if the asset is converted into stock-in-trade or the wholly owned relationship ceases within eight years.